- 505 - In addition, respondent argues that the testimony of Mallin and Uhl is suspect and not credible. We agree with respondent. At the outset we observe, contrary to certain facts alleged by IRA, that this record clearly establishes that IRA was engaged in the practice of purchasing tax benefits, rather than buying and leasing computer equipment for economic, profit-oriented reasons. To fully appreciate IRA's tax motivation for entering into these leasing transactions, we have considered them in the context of the schemes and other issues raised in these consolidated cases. There is no doubt that IRA was a vital cog in Kanter's sophisticated financial machinations. IRA, Holding Co., the "black box" represented by Administration Co. and Principal Services, and the other various investment entities created as alter egos of Kanter, constituted devices by which Kanter received and disguised fees for his personal services, including moneys received pursuant to the Prudential scheme. When these matters are viewed in context, we are persuaded that the leasing transactions were consummated for the sole purpose of producing deductions sufficient to offset the income reported on IRA's Federal income tax returns. Furthermore, to ensure that no net income would have to be reported by IRA, all of the equipment was effectively disposed of after the tax benefits were fully utilized.Page: Previous 495 496 497 498 499 500 501 502 503 504 505 506 507 508 509 510 511 512 513 514 Next
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